(November 23)   By Gail Fry
Lake Arrowhead Community Services District, the agency that provides water and sewer services for the resort community of Lake Arrowhead, has been facing increasing scrutiny from the Lahontan Regional Water Quality Control Board of late with regard to its sewage spills and failure to follow procedural requirements.
The majority of the sewage spills are the result of inflow and infiltration which occurs  when groundwater and/or storm water enter(s) the dedicated wastewater system to the point the system is overwhelmed. This results in sewage overflows, such that a portion of the effluent is not directed to a pumping station or treatment plant.
Mark Veysey is the interim general manager of the Lake Arrowhead Community Services District (LACSD). Veysey admitted the capacity of the district’s outfall line is 4-million gallons and in extreme rainstorms levels can rapidly reach 12-million gallons, resulting in excess sewage water spilling into an unnamed creek near its Grass Valley Wastewater Treatment Plant, then into Deep Creek, subsequently reaching the Mojave River. He said the problem has existed for about 30-years.
The Lahontan Regional Water Quality Control Board (Lahontan) attributed the high discharge to inflow/infiltration (I&I) while referring to past incidents where “significant discharges of raw and partially treated sewage from the collection and wastewater treatment systems to surface waters occurred and continue to occur.”
The problems with inflow and infiltration reached a critical point when during the winter of 2010/2011 approximately 9.5 million-gallons of partially treated wastewater was discharged into Grass Valley Creek, eventually dumping downstream into the Mojave River.
On December 7, 2011, Lahontan issued an investigative order demanding answers from LACSD. Lahontan’s investigative order required LACSD to submit two technical reports, one providing a detailed accounting of the district’s past inflow/infiltration reduction activities and an evaluation of their effectiveness and another providing the current status of implementing the inflow/infiltration elements of the district’s March 2008 wastewater facilities master plan and the current status of the district’s ability and mechanisms to fully finance the master plan’s inflow/infiltration abatement elements on schedule.
According to Lahontan, the substantial discharge was the result of I&I and “in spite of the district’s past efforts, significant discharges of raw and partially treated sewage from the collection system and wastewater treatment system to surface waters continue to occur.”
Lahontan credited the substantial I&I to “average annual rainfall of approximately 40 inches” with “a service area that ranges in elevation from 4,000 to 6,000 feet” above sea level coupled with “40 percent of the service area” on land that slopes greater than 30 percent. Lahontan also attributed the inflow and infiltration to “a limit of 4.0 million gallons per day of treated effluent that can be exported to the district’s Hesperia disposal area” and “a sewer collection system that can deliver up to 12 million gallons per day of untreated wastewater.”
In its investigative order Lahontan references several cease and desist orders it issued to Lake Arrowhead Community Services District related in part to “address excessive” inflow and infiltration conditions on May 12, 1983, September 8, 1983, January 12, 1984, July 13, 1984, May 13, 1993 and May 7, 1998.
Lahontan noted if the district implements the steps laid out in its 2008 master plan, the inflow and infiltration reduction activities “will reduce extreme wet weather flows from 12.0 million gallons per day (January 11, 2005 measurement) to 5.37 million gallons per day in 2030.”
Lahontan’s Cease and Desist Order No. 6-93-44 called for LACSD to submit progress reports summarizing accomplishments toward obtaining compliance with waste discharge requirements … until such time that compliance … is achieved.”
On February 21, 2012 LACSD experienced another sewage spill when 18,000-gallons of sewage entered Lake Arrowhead after a blockage of a sewage pipe resulted in backed-up  sewage overcoming a manhole, resulting in  the sewage entering Blue Jay Bay.
In responding to Lahontan on April 20, 2012, LACSD explained “under all but the most extreme wet weather conditions, the district’s collection system meets or exceeds USEPA and Regional Board standards” while admitting “under extreme wet weather conditions I&I in the district’s collection system does not always meet these standards.”
LACSD added “more specifically, emergency discharges from the district’s Grass Valley Wastewater Treatment Plant to Grass Valley Creek occurred during extreme wet weather conditions in 2010, 2008, 2005 and prior to that in 1998.”
LACSD explained, “Because these emergency discharges have only occurred during extreme and prolonged wet weather conditions, it is the district’s understanding that the potential adverse impacts to the environment are limited based on extensive monitoring, data collection and analysis of potential impacts to the environment that have been performed under the guidance and direction of regional board staff.”
A report on LACSD I&I activities from 2008 through 2011 provided to Lahontan showed LACSD has spent $9,131,000 on completing inflow and infiltration elements of its March 2008 wastewater facilities master plan.
LACSD spent the $9,131,000 on developing an Infosewer hydraulic model of the LACSD collection system, conducting a temporary monitoring of sewer flow, installing three rain gauges to measure rainfall, conducting 486,807 feet of closed circuit video inspection of its sewer, sealing and inspection of 5,575 manholes, repairing 217 manholes, smoke testing 48,420 feet of the collection system, completing 20 cured-in-place pipeline inner liner repairs, conducting 1,329 feet of pipe repairs, slip lining 30,840 linear feet of sewer pipe, rehabilitating 162 manholes and reinstalling 246 laterals.
Ongoing I&I activities shown in LACSD’s April 20, 2012 report to Lahontan indicate LACSD budgeted for and conducted sewer flow monitoring system-wide, analyzing flow data, identifying target sub-basins to focus future efforts to reduce I&I, and planning a system-wide hydraulic model calibration/cost effectiveness analysis, which is pending due to limitations and technology advancements.
With regard to LACSD’s response to Lahontan’s investigative order, Lahontan found the district’s response did not comply in that it did not provide a clear path toward fixing its inflow and infiltration issues in a timely manner or provide how the repairs would be paid for.
Veysey in his capacity as LACSD’s interim general manager conducted a series of meetings with Lahontan during August through September in order to assure Lahontan of its intent to address its ongoing inflow and infiltration problems and reach a consensus on what actions would be satisfactory to Lahontan.  He reported, “They were concerned that we were not complying with their rules and they were ready to go into enforcement on this district.”
Driving the point home to LACSD was Lahontan’s  imposition of an administrative civil liability in the amount of $700,000 on Victor Valley Wastewater Reclamation Authority in September 2012 for two unauthorized wastewater discharges from its wastewater treatment facility occurring on June 18, 2010 and August 22-28, 2010 as well as three additional unauthorized wastewater discharges from its sanitary sewer collection system on December 7, 2010, December 22, 2010 and December 27, 2010.
Lahontan provided LACSD with a deadline of October 1 in its August 21 letter to submit an addendum to its April 20, 2012 letter where it submitted its 2008 Wastewater Facilities Master Plan Status Report and Past Inflow/Infiltration Activities Report.
On July 18, Lahontan conducted an inspection of the Lake Arrowhead Community Services District’s sanitary sewer system.
On September 30, LACSD submitted its addendum to Lahontan acknowledging in extreme wet weather events they experience a significant rise in flows to its treatment plants caused by storm water entering its sewer system through cracks in pipes and damaged private lateral connections to the main line.
In its inflow remediation plan submitted to Lahontan with its September 30 letter, LACSD acknowledged there were only two solutions to remedy the problem of peak flows, which consisted of  “add[ing] a retention pond for peak storage or eliminat[ing] the sources of the inflow” while noting “new large sewage retention ponds are not an acceptable solution in the mountains.”
LACSD identified its Grass Valley Basin as the area where a majority of the inflow and infiltration was occurring and proposed deploying monitoring stations at key points in the 325,000 feet of sewer line and where approximately 2,200 sewer connections lead to its sewer collection system.
LACSD’s initial plan is to place twelve flow monitoring devices in locations at the downstream of individual collection basins. These will be in use for approximately six months, and as leaks are found they will be repaired.
On September 19, Lahontan issued a notice of violation to LACSD for not reporting its sanitary sewer overflows into private buildings, not conducting annual staff training on its overflow emergency response plan and eliminating its fats, oils and grease program.
According to documents, an overview of the areas evaluated during the inspection indicated LACSD’s sanitary sewer overflow (SSO) history, its SSO reporting and documentation, its overflow emergency response plan and its fats, oils and grease (FOG) program are all unsatisfactory.
With regard to LACSD’s SSO history, Lahontan provided that “on five occasions between July 18, 2011 through July 17, 2012, untreated wastewater was discharged from the collection system to waters of the United States.”
Additionally Lahontan found LACSD had not reported SSO’s that discharged to buildings/residences, failed to train its staff annually on the overflow emergency response plan and failed to implement its FOG control program calling for inspections of food serving establishments.